Bakery and Cereal Professional Organizations Send Feedback on Acrylamide Regulation


The European Commission’s measures to reduce acrylamide levels in food took a step forward, as new draft proposals outline “benchmark” mandatory levels for the industry. Bakery industry organizations from all over the Europe reacted and sent comments to the EC draft, many of them criticizing acrylamide levels set for bakery products and the insufficient categorization of bread types.

The draft project, published on the European Commission (EC) website, asks producers to apply mitigation measures to reduce the levels of the chemical in products such as biscuits, crackers and crispbreads, bread and breakfast cereals (excluding porridge).

When the benchmark levels are exceeded, food business operators have to review the applied mitigation measures and adjust processes and controls, according to the project. They must take into account the safety of foodstuffs, specific production and geographic conditions or product characteristics in view of achieving the benchmark levels.

For this, bakery producers have to monitor the level of acrylamide in finished products, to verify that the mitigation measures are effective in keeping acrylamide levels below the benchmark level – according to the draft project.

Benchmark levels for the presence of acrylamide in bakery foodstuffs referred to in Article 1(1) of the CEE project are as follows:  

FoodBenchmark level [µg/kg]
Soft bread

(a) Wheat based bread

(b) Soft bread other than wheat based bread




Breakfast cereals (excl. porridge)

– bran products and whole grain cereals, gun puffed grain

– wheat and rye based products (*)

– maize, oat, spelt, barley and rice based products (*)

(*) non-whole grain and/or non-bran based cereals. The cereal present in the largest quantity determines the category.





Biscuits and wafers

Crackers with the exception of potato based crackers


Ginger bread

Products similar to the other products in this category







Baby foods, processed cereal based foods for infants and young children excluding biscuits and rusks


Biscuits and rusks for infants and young children



In 2015, the European Food Safety Authority (EFSA) published its scientific opinion on acrylamide in food. Experts from EFSA’s Panel on Contaminants in the Food Chain (CONTAM) have reconfirmed previous evaluations that acrylamide in food potentially increases the risk of developing cancer for consumers in all age groups. This conclusion has not changed since the draft opinion was made available for an open public consultation in July 2014. Evidence from animal studies shows that acrylamide and its metabolite glycidamide are genotoxic and carcinogenic: they damage DNA and cause cancer, according to EFSA.


The Commission’s indication to set “limits” or even legal maximum levels for acrylamide in certain foods is a critical step, writes the International Association of Plant Bakers (AIBI), as it could reduce market availability of traditional bread varieties, which are highly appreciated by consumers.
AIBI members are worried about the lowering of the benchmark levels in Annex IV for bread, as they fear that some traditional bread varieties may not be marketed anymore. “In this context, it becomes obvious that the present two bread categories are too simplistic to reflect the large diversity of bread in a meaningful and representative manner. AIBI therefore proposes to establish more bread categories, which provide a more accurate and representative categorization of traditional varieties of bread and to discuss this approach transparently and openly with the European Commission and other stakeholders.”


Safe Food Advocacy Europe (SAFE) welcomes the reduction of the benchmark levels, as previous numbers were often higher than levels that can currently be found inside various products on the market.

SAFE mentions the current draft does not provide sufficient incentives for food business operators to comply and reduce high acrylamide levels, according to SAFE. “Indeed, although they are invited to apply the mitigation measures detailed in the annexes, their compliance is not ensured, as nowhere in the text can be found references to any sort of penalty, such as a product’s withdrawal from the market,” they add. The continuous general reliance on food business operators’ self-monitoring does not seem to be a sufficient incentive for them to effectively put in place mitigation measures provided in the annexes; therefore, SAFE would like the involvement of public authorities more clearly laid out in the regulation. SAFE also mentions that the suggestion made in Annex III (part II, point 1) would leave room for much uncertainty: the “Analysis of acrylamide can be replaced by measurement of product attributes (e.g. color) or process parameters”. This phrasing leaves unclear how such measurement could abide by scientific standards, and thus be of any value, says SAFE.


The European Consumer Organization (BEUC) says that its members remain convinced that legally-binding limits are needed if we are to achieve a significant lowering of acrylamide levels in Europeans’ food. Unlike the envisioned measures, legal limits would apply equally to food imported into the EU.

The proposal now on the table is a first step in the right direction, though, according to BEUC. The organization welcomes the Commission’s indication that it will set limits for acrylamide in certain foods.

BEUC also welcomes the comeback of the ‘ALARA’ (‘As Low As Reasonably Achievable’) principle. It should be clarified that it is the levels of acrylamide in food products that should be ALARA – and in any case below the benchmarks, says BEUC. “We would disagree that the benchmarks themselves have been set at ALARA levels, when they are based on the 85th or 90th percentile of acrylamide occurrence data. It is positive that the benchmarks have been set at levels lower than the current acrylamide ‘indicative values’ but they should be regularly reviewed to foster a continuous reduction of acrylamide in food.”

BEUC is concerned with the lack of detailed enforcement-related provisions in the proposal. It is vital that member states perform regular enough controls and share the analytical results from their controls with EFSA, as this will allow keeping track of the progress achieved – and in case it is insufficient, take further action. Own-checks by industry operators cannot replace independent control by national authorities, the organization mentions.

German Baker’s Confederation

German craft bakeries shall not be confronted with unfeasible requirements in order to reduce the acrylamide content in their products at a level that endangers traditional recipes, writes the German Baker’s Confederation. All legal binding measurements and benchmark levels shall be based on scientific data and not on pragmatism.

The confederation says that several improvements with respect to the demands of SMEs have already been included, and another important improvement is the appreciation of extended yeast fermentation as a mitigation measure, which can be implemented easily in each craft bakery.

“We deem it as worrying that avoiding a “dark roasting of the crust” is still enlisted in the mitigation measures in part A of annex II. The color of the crust doesn’t have any influence on the content of acrylamide in bakery wares. A dark dough as a result of the use of dark ingredients will lead in every case to a dark crust (e. g. in pumpernickel), but this doesn’t mean that such a bread is “burnt” or “unhealthy”. Quite in contrary, wholegrain products, which are high on fiber, always have darker crust, since wholegrain flour is naturally darker than plain, white flour. Therefore, any regulation that incriminates dark products (e. g. wholegrain products) as “unhealthy” or otherwise adverse should be cancelled,” the Confederation writes.

The most adverse change compared to former revisions of the draft is the considerable lowering of the “benchmark values” in annex IV. The confederation cannot see any scientific approach for this and no newly published data is available. Former benchmark values have already been challenging enough for craft bakeries, but recent values are hazardous.


The Federazione Italiana Panificatori (FIPPA) mentions some unclear articles and wonders if products that cannot be adjusted to the benchmarks can be sold anyway, mentioning the bread or pizza baked in wood burning oven.
It would also be desirable, adds FIPPA, that financial support for EU innovation and research projects defined for the period 2013-2020 should specify adequate financial measures toward a better understanding of the subject, which certainly concerns a major aspect in the health of all European consumers, the Italian federation adds.


The federation of Large Bakeries of Belgium (FGBB vzw/asbl) underlines that its member companies take their responsibility and strive to lower the acrylamide level as low as reasonable achievable. However, it points out that the two categories of “soft bread” which are taken in consideration do not cover the large diversity of breads. “We would strongly insist for more bread categories which provide a more accurate and representative categorization. Those categories should be linked to adjusted achievable benchmark levels. Moreover, FGBB fears that the introduction of “maximum levels”, instead of benchmark levels, would possibly reduce the traditional varieties of bread.”


The Swedish Food Federation (Livsmedelsföretagen) mentions that it would be practically impossible to control the acrylamide content in each individual package of food, given the variability of acrylamide levels that will always occur as a result of factors out of the direct control of the manufacturer, e.g. seasonal and geographical variation in raw materials.

They welcome that the concept of benchmark levels has been clearly defined in the draft regulation, in the hope that it will reduce the risk of misunderstandings when implementing the legislation. “In the case of breakfast cereals, it also seems odd that the benchmark level for bran products and whole grain cereals is the same as for wheat and rye based products, whilst it is well known that bran and whole grain products has a higher risk of acrylamide formation due to higher asparagine levels,” the federation writes.

They add that there should also be a consensus that measures must be proportionate to the resources and capacity of the many small and micro enterprises in the bakery sector.


The European Chocolate, Biscuit and Confectionery Association (CAOBISCO) is concerned that the database used to establish the ‘benchmark levels’ (BLs) is not representative and does not reflect appropriately the full diversity of products (including those based on bran/wholegrain) in Europe in all geographical regions and from small and larger food business operators. Accordingly, they expect that the lower BLs in comparison to the current Indicative Values will lead to a higher percentage of products exceeding the BLs than the level of exceedance used for calculation on basis of the database.


The European Confederation of National Bakery and Confectionery Organizations (CEBP) writes that, since most scientific studies show that the presence of acrylamide is much lower in cereals than in potatoes and coffee, we suggest that point (3) of the introduction finishes as follows: “..such as potatoes, coffee beans and cereals”.

Since HACCP methods are excessively expensive for micro FOBs, they consider that only the CoP of UEAPME – specifically designed for them – should be applicable to craft bakeries/confectioneries.
CEPB considers that the most adverse change compared to former revisions of the draft is the considerable lowering of the “benchmark values” for soft bread in annex IV. “We can’t see any scientific approach for this; no newly published data is available. Former benchmark values have already been challenging enough for craft bakeries, but recent values are hazardous. Even the EFSA’s opinion concerning acrylamide in food in June 2015 states that “results from human studies provide limited and inconsistent evidence of increased risk of developing cancer in association with dietary exposure to acrylamide” and thus that “more research is needed to confirm these results from human studies”. Therefore, there’s no scientific background for this change in the legislative procedure,” CEPB notes.


Intercéréales, the inter-branch organization representing the French cereal sector, criticizes the mentioning of sulphur and nitrogen fertilization.

The generalization of such recommendations should only be made on the basis of solid scientific arguments, according to the organization. “Otherwise, it is the supply chain as a whole, and first of all grain farmers, which would be penalized, with no guaranteed improvement in the consumer’s health. Moreover, these recommendations seem to be not pertinent or even contrary to current fertilization practices. Indeed, excessive nitrogen fertilization is not voluntarily implemented by farmers, given their economic and environmental objectives. Split nitrogen fertilizer application is now widespread in France, with a national average of three deployments in the case of wheat,” according to Intercéréales.

The organization recommends that research on the influence of agronomic conditions, especially nitrogen fertilization, on asparagine content of the grains be undertaken prior to any introduction in regulation of good agricultural practices recommendations.


The Federation of European Union Manufacturers and Suppliers of Ingredients to the Bakery, Confectionary and Patisserie Industries (FEDIMA) is concerned that the proposed mitigation measures are setting a strict enforcement on business operators. “Stated as is, these measures form important restrictions for food production and do not leave enough flexibility to reach mitigation targets for acrylamide. The provisions are deemed extremely prescriptive in the sense that they do not include elements such as ‘where recipe permits’ or ‘without affecting quality or organoleptic characteristics’,” according to the federation.


The European Breakfast Cereal Association (CEEREAL), representing the breakfast cereal and oat milling industry, says that the proposed benchmark level of 300 µg/kg (reduction from 400 µg/kg) for the category ‘bran and whole grain cereals and gun-puffed grains’ is impractically low, because it is based on data that is not representative. It is well known that bran and whole grain products have a higher potential risk of acrylamide formation (compared to other breakfast cereals), due to the higher content of asparagine in the bran layer of grains.

“While we understand the intention of setting ambitious benchmark levels, it is our understanding that the proposed level of 300 µg/kg is based on datasets containing products manufactured with different temperature processing conditions. The muesli recipes can include steam treated whole grain and other ingredients with low acrylamide, so significantly diluting the final acrylamide result. For this reason, we suggest that the current Indicative Value of 400 µg/kg should be maintained for the category ‘bran and whole grain cereals and gun-puffed grains’, and the category ‘muesli’ excluded from the scope of the proposed legislation,” CEEREAL writes. 

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